Key Takeaways
- HMRC and HM Treasury launched a joint call for evidence on 16 July 2026, asking whether the UK’s declaration-based customs model is still fit for purpose
- The consultation closes on 15 September 2026 — traders, intermediaries, freight forwarders, hauliers and software providers are all invited to respond
- HMRC’s Customs Declaration Service cleared over 91 million declarations in 2025, but the government questions whether declarations at a single point still match how digital supply chains operate
- The call for evidence explores shifting from separate declarations to data drawn directly from electronic trade documents and supply chain systems
- HMRC is already testing AI tools for its Online Trade Tariff and running joint data-exchange pilots with US Customs and Border Protection
- Responses can target specific sections — HMRC explicitly welcomes partial answers
What the Call for Evidence Is Asking
On 16 July 2026, HMRC and HM Treasury jointly published “Modernising the UK Customs Regime,” a call for evidence that asks a fundamental question: is the UK’s current customs model — built around declarations submitted at a single point in a goods movement — still the right approach for a trading world that runs increasingly on structured digital data?
The call for evidence is open for twelve weeks, closing on 15 September 2026. It is led jointly by HMRC’s R Holt and HM Treasury’s T Smiles. The foreword, signed by Dan Tomlinson MP, Exchequer Secretary to the Treasury, frames this as the next chapter after several years of foundation-building since EU Exit.
The consultation is explicitly linked to a separate HMRC consultation on mandatory registration for customs intermediaries, published the same day. HMRC encourages respondents to engage with both, since they address complementary parts of the future customs and intermediary landscape.
Importantly, HMRC does not expect respondents to answer every question. The consultation document invites partial responses — respondents can focus on the sections most relevant to their experience. This lowers the barrier for smaller traders and intermediaries who may not have the resources to respond to a full consultation in detail.
The Current Customs Landscape: What Has Been Built So Far
Since leaving the EU, HMRC has delivered several major pieces of customs infrastructure:
- Customs Declaration Service (CDS) — the replacement for CHIEF, which cleared over 91 million customs declarations into and out of the UK in 2025, according to HMRC figures
- Goods Vehicle Movement Service (GVMS) — the system that handles pre-lodged declarations for goods moving via roll-on roll-off ports
- Windsor Framework customs arrangements — the specific procedures for movements between Great Britain and Northern Ireland
These systems form the operational foundation. But the call for evidence argues that having stood up the infrastructure, the government now needs to ask whether the underlying model — a declaration submitted at a single point — matches how modern supply chains actually work.
For operators already navigating CDS declarations, this matters. Any shift away from the declaration-based model would change what data you submit, when you submit it, and potentially which systems you interact with at the border.
Digital Trade: How Far It Has Already Moved
The call for evidence sets out just how far trade digitalisation has progressed — and the pace is accelerating.
The Electronic Trade Documents Act 2023 gave electronic trade documents, such as Bills of Lading and air waybills, the same legal standing as their paper equivalents. According to HMRC’s own analysis, this change is estimated to deliver a net benefit of around £1.14 billion to the UK economy over a decade through reduced administrative costs.
Internationally, major container shipping carriers have committed to 100% adoption of electronic Bills of Lading by 2030. A 2024 industry survey found that roughly half of supply chain participants already use electronic Bills of Lading in some capacity. The trend is unambiguous: paper is on the way out.
Other customs authorities are moving in parallel. The EU’s Customs Union reform programme sets out plans to replace traditional declarations with data flowing directly from digitalised trade systems, alongside AI-enabled risk assessment. US Customs and Border Protection is continuing to modernise its own centralised import and export platform, with a focus on interoperability and trusted data sharing.
For UK operators who import from the EU or trade with the US, these parallel modernisation programmes will affect how they interact with customs systems on both sides.
The Core Question: Declarations vs Supply Chain Data
The heart of the call for evidence — and arguably its most consequential section — asks whether HMRC’s data model itself needs to change.
The current approach relies on information submitted through a customs declaration at a specific point in a goods movement. HMRC notes that previous UK border technology pilots have already shown that most customs risk data requirements could, in principle, be met using electronic trade documents and other data drawn directly from digital trade and inventory systems, rather than being separately keyed into a declaration.
This is where AI enters the picture directly. HMRC points to work already under way: two customs digitalisation pilots announced at Tax Update 2025, one testing how digital trade data and documents could feed into HMRC systems, and a second — run jointly with US Customs and Border Protection — testing data exchange and digital verifiable credentials as a way of building cross-border trust.
Separately, under its Transformation Roadmap, HMRC has begun using AI tools to improve its Online Trade Tariff service. The call for evidence asks whether supply chain data — shipment information, inventory records, transport documents — could eventually replace the need for a separate customs declaration altogether, or at least reduce the data that has to be manually entered.
For traders who currently manage customs declaration errors and corrections, this shift could significantly reduce the error surface. Fewer manual data entries means fewer opportunities for mistakes — and fewer C285 duty refund claims for overpaid or misdeclared goods.
The call for evidence also explores how data from existing systems — warehouse management software, transport management platforms, inventory ledgers — could flow into HMRC systems in near real time, rather than being re-keyed into a declaration. This would represent a structural change in how customs data is gathered, moving from a submission model to a data-sharing model. For operators with mature digital systems, this could reduce compliance cost. For smaller traders with less digital maturity, it raises questions about what support would be available.
The question HMRC is asking is not whether to abolish declarations overnight, but whether the current model is the right long-term default. The consultation explicitly asks respondents to identify which parts of the current declaration process add value and which are duplicative of data already held in commercial systems.
What This Means for Traders, Intermediaries and Software Providers
The call for evidence is not a policy announcement — it is a genuine consultation. But the direction of travel is clear, and it has implications for every part of the customs ecosystem.
For importers and exporters: If HMRC moves toward a supply-chain-data model, the systems you use for inventory, transport and trade documentation could become more directly integrated with customs. This could reduce the burden of separate declaration submission, but it also means your commercial systems need to be accurate and audit-ready, because the data flowing through them would feed customs processes directly.
For customs intermediaries and freight forwarders: The role of the intermediary could shift. If declarations become less central, the value proposition of intermediaries may move toward data quality assurance, systems integration and compliance advisory work rather than data entry. This is why the parallel consultation on mandatory intermediary registration matters — it signals government thinking about who should be allowed to act in this space. The introduction of PAS 41201:2026 as the new customs intermediary standard is part of the same landscape.
For software providers: If HMRC’s future model draws on electronic trade documents and supply chain data, software that currently focuses on declaration submission may need to pivot toward data interoperability, API integration with trade documents, and real-time data sharing with HMRC systems. The providers who build this capability early will have a competitive advantage.
For traders dealing with commodity code classification: HMRC’s AI-enhanced Online Trade Tariff is already live and improving. If supply chain data increasingly feeds customs processes, accurate classification at source — in commercial systems — becomes even more critical, because there may be fewer manual correction points downstream.
**For AEO-certified operators and those considering trusted trader status: The call for evidence could reshape the trusted trader landscape. If data sharing replaces declarations, the criteria for trusted trader status may evolve. Operators who invest in data quality and systems integration now will be better positioned for whatever model emerges.
The consultation also asks about the role of customs intermediaries in a future digital system. The parallel consultation on mandatory intermediary registration, published the same day, asks whether all businesses providing customs services should be required to register with HMRC. Together, these two consultations signal government thinking about raising professional standards in the intermediary sector — which would directly affect the 3PL onboarding process for businesses outsourcing customs work.
Key Dates and How to Respond
| Date | Event |
|---|---|
| 16 July 2026 | Call for evidence published |
| 15 September 2026 | Consultation closes (12-week window) |
| Within 12 weeks of close | HMRC and HM Treasury aim to publish summary of responses |
Responses should be submitted via the GOV.UK consultation portal. HMRC encourages respondents to focus on the sections most relevant to their experience — partial responses are explicitly welcomed.
The call for evidence sits alongside the HMRC Transformation Roadmap, published in July 2025, which sets a target of at least 90% of HMRC customer interactions being digital by 2030. As of mid-2026, 78% of customer interactions are digital, with 7.6 million unique HMRC app users and nearly 20 million Personal Tax Account users. Customs modernisation is one strand of this broader digital transformation.
For operators who want to understand the current declaration framework before responding, the UK customs clearance step-by-step guide covers the existing process in detail.
Frequently Asked Questions
What is the HMRC customs modernisation call for evidence? It is a joint consultation by HMRC and HM Treasury, published on 16 July 2026, asking whether the UK’s declaration-based customs model is still fit for a world of digital trade. It closes on 15 September 2026.
Who should respond to the consultation? HMRC is inviting responses from traders, intermediaries, freight forwarders, hauliers and customs software providers. Partial responses focusing on specific sections are explicitly welcomed.
What could change as a result? The call for evidence could lead to a shift from separate customs declarations toward data drawn directly from electronic trade documents and supply chain systems. It could also accelerate AI use in customs risk assessment and tariff classification.
Does this affect existing CDS declarations? No immediate changes. CDS remains the operational customs declaration platform, having processed over 91 million declarations in 2025. Any shift would follow the consultation summary and subsequent policy decisions.
How does this relate to the Single Trade Window? The Single Trade Window — a single digital gateway for border requirements — is part of the broader BTOM framework. The call for evidence explores how customs data could flow through such systems more efficiently, potentially reducing the need for separate declaration submission.
Is this connected to the EU-UK SPS agreement negotiations? The SPS agreement negotiations are a separate track, though both are part of the wider border modernisation agenda. The customs call for evidence focuses on the data model for customs processes specifically.